Our policies

BABY JEWELLERY, S.L. as a member of the Responsible Jewellery Council (RJC) expresses its adherence and commitment to ethical business practices and compliance with the requirements of the RJC Code of Practice (CoP) in all its business activities relating to precious metals and gold jewellery.

The management of BABY JEWELLERY, S.L. will progressively implement responsible ethical, social and environmental best practices throughout its precious metals supply chain, from mining to retail. As a responsible entity in the precious metals supply chain, we value the trust of our customers and end- consumers in our business group and ask our business partners to adhere to it.

As part of our best efforts and as a responsible business group, we seek and require the cooperation of all our business partners in order to effectively implement the RJC standards and ensure that the entire precious metals supply chain complies with business, social and environmental responsibilities.

We strongly encourage all our business partners to inform themselves about, adhere to and implement the requirements of the RJC Code of Practice (CoP), as well as other internationally recognised platforms, entities or standards in these areas.

You can find more information about the Responsible Jewellery Council (RJC) at the following link: http://www.responsiblejewellery.com


BABY JEWELLERY, S.L. undertakes to:

1. Ensuring that all business and commercial activities are conducted in an honest, ethical, responsible and professional manner is fundamental to the principles and values of our organisation.

2. All companies within the corporate group are committed to combating dishonesty and fraud in all business transactions, with the aim of maintaining and enhancing consumer confidence and the reputation of the jewellery and precious metals sector and industry.

3. The companies of the business group will strive to obtain and align commitments from their business partners.

4. For the benefit of all its stakeholders, the corporate group is committed to implementing and maintaining the

highest standards of economic and financial integrity.

5. All accounting records and reports generated from those records shall be prepared and maintained in

accordance with the legal framework applicable at any given time and jurisdiction.

6. Ongoingcompliancewithgenerallyacceptedaccountingprinciplesinthecountrywherethegroupcompanies

are incorporated and registered is required, as well as the system of internal controls implemented.

7. It is the responsibility of all companies in the business group to seek to improve and enhance their business value through best business practices. Our business activities have a direct and indirect impact on the organisations with which we operate and therefore good business practice requires that business decisions take into account the requirements, needs and expectations of its stakeholders, including shareholders, customers, employees,

suppliers, business partners and local communities.

8. AllemployeesofallourcompaniesmuststrivetoconductthebusinessofBABYJEWELLERY,S.L.inaccordance

with these principles.

9. Whenmakingbusinessdecisions,employeesmustactinaninformedmanner,ingoodfaithandwithanhonest

belief that the action taken is beneficial and in accordance with the company's principles, values, policies and


10. BABY JEWELLERY, S.L. has implemented programmes that periodically monitor the effectiveness of these

commitments and therefore support all employees in this effort.

11. AllthecollaboratorsofBABYJEWELLERY,S.L.willoperateinaccordancewiththelegislativeframeworkandthe

pertinent national and international regulations applicable at all times in the countries in which they operate.

12. All personnel are expected and required to comply with all applicable laws and regulations, as well as with all internal policies, procedures and standards of the corporate group, related to their business and commercial activities. It is the responsibility of all personnel to know, understand and consistently apply all legal, regulatory

and internal requirements applicable to their jobs and activities.

13. In order to maintain and enhance customer confidence and the reputation of the jewellery and precious metals

industry, the group is committed to providing the necessary means at its disposal to ensure that all economic and commercial processes and transactions under its control are conducted in a professional, ethical, environmentally friendly and socially responsible manner.

14. BABY JEWELLERY, S.L. has defined and adopted a document of Business Principles and a Code of Conduct that establishes the basic rules to be observed by all directors, employees, collaborators and third parties.

15. BABY JEWELLERY, S.L. has defined and adopted policies relating to "Legislation and regulations" and "Doing business ethically, with integrity and fairness".


Our commitments:

1. BABY JEWELLERY, S.L. and its employees undertake to prohibit bribery and facilitation payments in all business practices and transactions carried out by them or by business partners on their behalf. No payments, gifts in kind, hospitality, expenses or promises shall be offered, accepted or approved as such that may compromise the principles of fair competition or constitute an attempt to obtain or solicit business for or with any person, or to redirect business to any person; to influence the course of business or governmental decision making.

2. BABYJEWELLERY,S.L.anditsemployeesconsidertheriskofbriberyandfacilitationpaymentsas it applies to their organisation (including agents) to identify which areas present high risks. BABY JEWELLERY, S.L. has developed appropriate methods to monitor the conduct of employees and agents and eliminate the risk of bribery based on this knowledge.

3. The management of BABY JEWELLERY, S.L. facilitates the reporting of incidents of attempted bribery, facilitation payments or inappropriate gifts within its corporate group and shall apply appropriate sanctions for bribery and attempted bribery in all its forms.

4. No employee shall suffer demotion, penalty or other adverse consequences for expressing a concern or for refusing to pay a bribe or facilitation payment or obtain a gift or similar, even if this action may result in the loss of company business.

5. For partners and entities where full elimination has not been achieved, appropriate controls will be implemented to monitor, supervise and fully account for all risks, with the ultimate goal of achieving their progressive reduction and elimination.


BABY JEWELLERY, S.L. undertakes to:

1. BABY JEWELLERY, S.L. recognises the fact that entities in the precious metals and jewellery sector have to take responsibility for analysing and assessing their potential vulnerabilities to money laundering and terrorist financing, as well as implementing systems and measures to prevent and protect against malpractice and abuse by criminals.

2. Strict compliance is required at all times with the applicable national and, where applicable, international legislative and regulatory framework on money laundering, terrorist financing, bribery, facilitation payments, corruption, smuggling, embezzlement, fraud, extortion, transfer pricing and tax evasion in all relevant jurisdictions.

3. All employees of BABY JEWELLERY, S.L. shall act in accordance with the annual legislative framework with regard to the obligation to audit and file annual accounts.

4. It is the responsibility of all personnel to know and understand the legal, regulatory and internal requirements related to the prevention of money laundering, terrorist financing and other possible non-compliance and/or relevant financial crimes that may affect the business group. Depending on the seriousness of the incident, ignoring or failing to report to the company suspicious economic and/or business activities that appear questionable may also be considered a violation of established business principles.


Our commitments:

1. BABY JEWELLERY, S.L. and its collaborating entities are committed to establish and implement the security measures of the products inside its facilities and along all the logistic processes of transport, reception, storage and expedition, to protect them against possible thefts, damages or substitutions.

2. The safety and well-being of employees, visitors and other relevant business partners is taken into consideration as a priority when establishing product safety measures.

3. All precious metals and jewellery sold by partners to consumers shall comply with the applicable legal standards and requirements for product safety and health.


BABY JEWELLERY, S.L. undertakes that the following essential principles will be applicable in all transactions of the entity involving precious metals and gold jewellery:

Full disclosure, i.e. full and complete publication of all available information about the precious metal and, if applicable, all material steps it has undergone prior to sale to the buyer, regardless of whether or not the information is specifically requested and regardless of the effect on the value of the item being sold.

There shall be no misuse of terminology, misrepresentations or attempts to disguise the product in the sale, advertising and distribution of precious metals.

BABY JEWELLERY, S.L. will perform risk assessment and identify contamination points in its processes and product life cycle. To address the identified contamination points, BABY JEWELLERY, S.L. will create a unique policy, procedure and training programme for each risk. Full disclosure at all times, including verbal disclosure prior to and during the sale, and written disclosure on each sales invoice, receipt, laboratory certificate or other documentation related to the sale in the appropriate local language. No terms should be used to obscure characteristics or to misinform the consumer.


The policies relating to this section form part of the Business Principles adopted by BABY JEWELLERY, S.L. and are set out below for reference:

"BABY JEWELLERY, S.L. will ensure that all claims of provenance made are fully valid together with the evidence available to support the claim(s)".

- Origin: Geographical origin of the material, e.g. country, region, mine or corporate ownership of the mining facility(ies); and/or

- Source: Type of source, e.g. recycled, mined, artisanal or date of production; and/or

- Practices: Specific practices applied in the supply chain related to the Code of Practice (CoP), including, but not limited to, standards applicable to extraction, processing or manufacturing, conflict-free status or due diligence towards sources.

Provenance claims can also relate to origin, sources or practices that are specifically excluded from the supply chain, such as through a "negative assurance".

BABY JEWELLERY, S.L. will ensure that all claims and statements (made to consumers or other businesses) about supply chain practices and the origin or source of precious metals (gold), through the use of descriptions and symbols, are valid.

BABY JEWELLERY, S.L. shall ensure that no attempt is made to mislead consumers by means of illustrations, descriptions, expressions, words, figures, representations or symbols relating to the provenance statement(s).

BABY JEWELLERY, S.L. will ensure that all employees are aware of the declaration of origin and its procedures.


This policy is applicable to the entire activity of BABY JEWELLERY, S.L. and with effect from 02 April 2024. It covers minerals and/or precious metals incorporated in its gold jewellery.

The management of BABY JEWELLERY, S.L. is committed to taking appropriate measures, including risk assessment and best efforts to ensure compliance of Level B entities with the Principles of Good Practice.

BABY JEWELLERY, S.L. will always obtain material from legitimate sources and will ensure compliance with the OECD guidelines on Conflict-Affected and/or High-Risk Areas (CAHRA).

BABY JEWELLERY, S.L. expects its suppliers to have sufficient and appropriate due diligence policies and measures in place to reasonably ensure that the products and components supplied to it contain only conflict-free minerals and metals.

As a responsible company, BABY JEWELLERY, S.L. supports the goal of the Dodd-Frank Act to prevent armed groups in conflict-affected countries from benefiting from the supply of conflict minerals and metals from that region.

BABY JEWELLERY, S.L. is committed to collaborate with its suppliers and collaborators to inform them about these aspects and about the actions that these can implement to obtain a greater transparency on the origin of the minerals and metals contained in the products that they manufacture and sell to BABY JEWELLERY, S.L.

BABY JEWELLERY, S.L. reserves the right to assess the extent to which a supplier has reasonably failed to comply with this policy.

BABY JEWELLERY, S.L. reserves the right to request additional documentation from its suppliers about the origin of the conflict minerals and metals included in the purchased products.

Suppliers who do not reasonably comply with this policy will be evaluated by BABY JEWELLERY, S.L. to decide on the suitability and appropriateness of entering into new transactions and business.


BABY JEWELLERY, S.L. undertakes to:

1. Comply at all times with applicable national and, where applicable, international employment and labour laws/regulations/conventions.

2. BABY JEWELLERY, S.L. will not require employees to work more than the national limit of hours in a week on a regular basis, with overtime not exceeding the national limit allowed per week on a regular basis, unless there are legal exceptions.

3. BABY JEWELLERY, S.L. will ensure that wages and benefits for a standard working week meet at least national minimum standards and are sufficient to meet workers' basic needs and provide some discretionary income.

4. Wages shall be paid to employees on a regular and predetermined basis in a form and location convenient to the employees, accompanied by a pay voucher detailing wage rates, benefits and deductions, as applicable.

5. It is the responsibility of the staff concerned to know and understand the legal, regulatory and internal employment-related requirements and conditions that apply to their jobs.

6. Where required, due recognition shall be given to the existence, membership and lawful activities of workers' representative bodies, and workers' representatives shall be given access to carry out their responsibilities/functions.

7. Internal and collective agreement procedures should be followed for the dismissal of employees, should the need for dismissal arise, and unfair dismissal procedures should be avoided.

8. Information on employment policies and applicable labour practices should be communicated in a transparent manner to all employees.


The policies relating to this section form part of the Commercial Policies adopted by BABY JEWELLERY, S.L. and are presented below by way of reference:

1. BABY JEWELLERY, S.L. will not prevent employees from associating and bargaining collectively.

2. Discrimination can mean distinction, exclusion or preference.

3. BABY JEWELLERY, S.L. rejects any form of discrimination in relation to the recruitment, dismissal, payment, promotion and training of employees on the grounds of race, ethnicity, caste, national origin, religion, age, disability, gender, marital status, physical appearance, sexual orientation, HIV status, migrant status, membership of workers' representative bodies, political affiliation or any criteria that is unlawful and any reported incident will be considered a serious breach of these policies.

4. BABY JEWELLERY, S.L. will ensure that employees who have certain life-threatening illnesses or conditions are not treated differently from other employees, and will continue to employ such personnel, provided that they are physically and mentally fit to attend to their normal job responsibilities.

5. Persons who are "fit for work" shall in all cases be given equal opportunities and shall not be discriminated against on the basis of factors unrelated to their ability to perform their work.

6. BABY JEWELLERY, S.L. will not use corporal punishment under any circumstances and will ensure that employees are not subjected to harsh or degrading treatment, sexual or physical harassment or other forms of mental or physical coercion, abuse or intimidation.

7. BABY JEWELLERY, S.L. encourages all personnel to express their concerns promptly if they have a legitimate reason to believe that a company policy, operation or practice is or is likely to be a violation of any law, regulation, rule or internal company policy.

8. BABY JEWELLERY, S.L. assures all employees who make complaints in good faith that they will be treated fairly and respectfully. While every effort will be made to protect the anonymity of employees to the extent possible, no form of retaliation against such persons will be tolerated, assuming they have not been involved in the breach.


BABY JEWELLERY, S.L. undertakes to:

1. No form of child labour must be accepted on any of the premises of BABY JEWELLERY, S.L. and its collaborators and/or business partners.

2. Unless local laws stipulate a more restrictive higher age, in the case of Spain sixteen years of age, the minimum age for employment that will be applicable is fifteen years (according to ILO Convention No. 138).

3. For authorised adolescents (persons under the age of 18 but over the age of 15), the management of BABY JEWELLERY, S.L. is responsible for providing working conditions, working hours and wages in accordance with the requirements set out in the applicable local legislation.

4. The ownership and/or management of employees and/or business partners shall ensure the implementation of this policy and compliance with the applicable legal framework of reference in this field.

5. If a child is found to be working on the premises of an employee and/or business partner, the non- compliance will be reported and responsibility for remediation will be assumed by the ownership and/or management of the offending organisation concerned. Any reported incident involving child labour will be considered a serious violation of our business principles.


BABY JEWELLERY, S.L. undertakes to:

1. That no forced or involuntary labour is practised in any form at any of its workplaces and associated activities. Any reported incident involving forced or involuntary labour will be considered a serious violation of our business principles.

2. The following definitions shall apply:

▪ The Universal Declaration of Human Rights which states that "No one shall be held in slavery or servitude".

ILO Convention 29, which 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 the said person has not offered himself voluntarily".


BABY JEWELLERY, S.L. undertakes to:

1. All employees of BABY JEWELLERY, S.L. will be treated with equality, respect and dignity.

2. BABY JEWELLERY, S.L. believes in and respects fundamental human rights in accordance with the United Nations Universal Declaration of Human Rights.

3. BABY JEWELLERY, S.L. will not interfere with the right of employees to observe principles or practices based on caste, race, national origin, gender, religion, disability, trade union membership or political affiliation.

4. BABY JEWELLERY, S.L. rejects any form of coercive, threatening, abusive or exploitative sexual behaviour.

5. BABY JEWELLERY, S.L. will not tolerate any reported incident involving physical, sexual, racial, religious, psychological, verbal or any other form of direct or indirect harassment or abuse, or any other form of intimidation or degrading treatment.


BABY JEWELLERY, S.L. undertakes to:

Ensure that our supply chain has not procured metals (gold) to support or benefit armed and anti-social groups in conflict or involving serious human rights abuses and non-compliance with the OECD Guidelines.

BABY JEWELLERY, S.L. considers such activities or non-compliance to be unacceptable under any circumstances, and will systematically reject any material that it considers to have been obtained through the violation of human rights or to have benefited or supported armed or terrorist groups through illegal financing or other activities.

BABY JEWELLERY, S.L. will carry out a risk assessment for its supply chain and will not enter into any business relationship or, if necessary, suspend/terminate engagement with any supplier involved in dealing with conflict-affected or high-risk areas. We reject and consider intolerable any form of human rights violations, torture, cruel, inhuman and degrading treatment, forced/compulsory labour, child labour, abuses such as widespread sexual violence, war crimes, other serious violations of international humanitarian law, crimes against humanity, genocide and/or bribing or being bribed. We condemn and strictly prohibit any direct/indirect support to public/private security forces that illegally control, tax or extort mining operations, artisanal processing and/or transport and trade routes.

BABY JEWELLERY, S.L. will carry out due diligence to assess the risks related to the procurement from Conflict Affected and High Risk Areas (CAHRA) and will always source from eligible miners/refiners/traders.

All reasonable efforts will be made to source precious metals from approved "Conflict Free" smelters and refiners, and our direct and indirect suppliers will be required to do the same.

We are committed to establishing a collaborative, ethical and supportive framework with the organisations that are part of our supply chain, which contributes to the progressive and systematic implementation of conflict minerals compliance programmes.


BABY JEWELLERY, S.L. undertakes to:

Ensure that precious metals mining and trade support peace and development rather than conflict.

BABY JEWELLERY, S.L. remains committed to improving its Supply Chain Due Diligence and supply chain risk assessment through internal reviews and external assessments. A zero tolerance policy is established for suppliers who violate OECD due diligence guidelines and we will immediately discontinue business relationships with suppliers who present reasonable indications or evidence of incurring a high risk assessment during our risk assessment.

BABY JEWELLERY, S.L. purchases its precious metals from suppliers committed to ethical business practices. However, a due diligence and risk assessment process has been progressively implemented and will be updated annually and reviewed when any significant risk is detected or any complaint or claim is received.


The Direction of BABY JEWELLERY, S.L., in the frame of its values, principles and policies, conscious of the importance of the aspects related to the management of the quality, the security, the health in the work and the environment, as well as of its repercussion in the efficiency of its processes, results, image, sustainability, satisfaction of its clients and specially in the well-being, physical and mental integrity of the people who integrate and are related to the organization, deploys and assumes the following commitments:

- Progressively integrate and implement a management system in accordance with the requirements of the applicable international and sectoral regulations of recognised prestige.

- Ensure adequacy and compliance with all applicable legal, technical, voluntary and customer requirements.

- Plan and manage efficiently all the resources and technology necessary to develop policies and achieve the established objectives and goals.

- Identify, control and improve the organisation's strategic, operational and support processes, in order to ensure the safety, quality and sustainability of these as well as of the products and services provided.

- Consult and encourage the active participation of all staff through the established mechanisms of representation, consultation, communication and training.

- To implement tools that, from an integral viewpoint, make it possible to identify, eliminate, assess, reduce and control those hazards and risks that may cause damage to health, assets, products and the environment.

- Protect the environment by identifying and assessing environmental aspects and impacts, prevent pollution, contribute to climate change mitigation and adaptation, and make sustainable and efficient use of resources.

- To provide safe and healthy working conditions at organisational, technical-material and environmental levels to prevent injuries and deterioration of health.

- Communicate this policy and all key elements of the system to all stakeholders.

- Establish, monitor and periodically evaluate the performance of the management system and the

results achieved.

- Implement mechanisms to ensure adequate change management, as well as to contribute to the continuous improvement of the organisation, its systems, products and processes.

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