Tacori Sourcing Policy
Tacori is committed to respecting the human rights of our employees and the employees of our suppliers, vendors, and contractors. Our Human Rights Policy Statement adheres to the principles of free choice of employment, nondiscrimination, and humane treatment. We are committed to ensuring compliance with regulations governing child labor, minimum wage, and maximum working hour limitations. Further:
- We are committed to fair labor practices within our supply chain.
- We leverage an audit system in partnership with the Responsible Jewellery Council (RJC) to identify and evaluate the potential risks for human trafficking and slavery in our supply chain.
- We require our suppliers to leverage a third-party assessment, following guidance from the Responsible Jewellery Council (RJC) COP and/or provide sufficient evidence of self-identification and self-evaluation of the potential risks for human trafficking and slavery in their supply chain.
- Tacori monitors supplier conduct through an established screening process, which takes into consideration the supplier’s geographic location and manufacturing processes, a workforce profile, the history of human trafficking and slavery in the sector, the U.S. Department of Labor’s list of goods identified as vulnerable to forced labor, and third-party reports concerning the supplier’s human rights record, if available.
- Tacori requires suppliers respond in writing to questions regarding areas of concern raised during the screening process. Tacori only engages with suppliers who have met the screening criteria for conduct in compliance with our Human Rights Policy and Supplier Code of Conduct.
- Grievances and/or questions relating to Tacori’s supply chain policies and supplier conduct can be directed to sourcing@tacori.com.
Labor Brokers and Third-Party Recruiters
Workers are a critical component of a company’s supply chain. Within a supply chain, labor brokers or third-party recruiters sometimes serve as the intermediary in the recruitment, hiring, and even management of workers.
- We are committed to fair labor practices in partnership with our labor brokers and third-party recruiters.
- On demand or by request, we will collect necessary documentation of the supplier’s third-party evaluation or self-evaluation of potential risks for human trafficking and slavery in their supply chain.
- We require foreign labor contractors to register with the Labor Commissioner and post bonds. Effective 2016, Senate Bill 477 (Steinberg) will also create an enforcement mechanism against employers who use unregistered compliance as part of their hiring process. Furthermore, when our internal auditors report an instance of abuse, our company then sends a professional third-party auditing firm to independently evaluate the suspicion.
Audits
Auditing is an important part of a company’s efforts to eliminate human trafficking from its supply chain, since human trafficking and forced labor are complex and often hidden. Both human trafficking and forced labor are characterized by deception and are the result of pressures, abuses, and exploitation levied not by a single employer, but by several abusive actors at different stages of the recruitment, hiring, and employment process.
- We are committed to auditing suppliers or vendors that are deemed high-risk or non-compliant within our supply chain, to determine if they are complying with our company standards aimed at ensuring human trafficking is not tainting our products.
- We decide which suppliers to audit based on assessing the risk level for slave labor or human trafficking practices in the country where the supplier operates.
- If an audit is performed, Tacori will disclose whether the auditors are independent.
Certification
Tacori is committed to certifying that materials incorporated into our product comply with the laws regarding slavery and human trafficking of the applicable country.
- To ensure that our contractors and suppliers respect and enforce our company standards, Tacori may include a clause in the commercial agreement governing our contractual relationship with suppliers, which stipulates that our suppliers must abide by our anti-slavery and human trafficking standards. Thus, as a condition of doing business with us, and as a means of self-certification.
- Tacori expects each manufacturing partner to maintain records that are sufficiently detailed to substantiate that all materials it supplies to us are produced in compliance with the anti-slavery and human trafficking laws of the country or countries where they are produced. Our partners must produce these records to our company auditors upon request. Such records may include: (1) proof of age for every worker; (2) every employee’s payroll records and timesheets; (3) written documentation of terms and conditions of employment; (4) local health and safety evaluations or documentation of exemption from law; and (5) records of employee grievances and suggestions, and any employer responses.
- We also use independent country, commodity, and product risk data annually provided by a global risk advisory firm to score, rank, and evaluate the human trafficking risks associated with what we buy and where we buy it. The results help us decide whether direct suppliers should complete a human trafficking risk self- assessment, or whether an independent human trafficking audit is justified.
- If Tacori determines that a direct supplier needs to complete a human trafficking risk self-assessment, Tacori will provide them with an affidavit through which they must affirm that they will review and comply with human trafficking and worker protection laws in their respective jurisdictions.
- Suppliers that may pose a risk may be required to complete a self-assessment, and the results of that assessment will assist Tacori in evaluating whether an independent third-party audit is needed.
Internal Accountability
Tacori encourages suppliers to comply with labor and anti-trafficking laws. Through periodic updates of such disclosure efforts, Tacori can best show how we are addressing human trafficking risks over time within our supply chain.
- Tacori discloses whether it has internal procedures for determining whether employees or contractors are complying with company standards regarding slavery and human trafficking.
- Tacori will readily provide a link to its code of conduct, if/when requested.
- If a company has internal procedures for determining whether employees or contractors are complying with company standards, the company is expected to explain to Tacori what these are to clarify the extent of its activity.
- Upon request or need, Tacori can provide general information on types of corrective and preventive action.
- Non-compliance with our company standards regarding slavery and trafficking can result in corrective action or termination, depending on the number of non-compliances found and their severity.
- While we believe in sustainable remediation, we reserve the right to terminate a business relationship with an employee or contractor if it is deemed necessary.
Worker Protections
Tacori is committed to sharing any mechanisms in place to help workers understand the company’s fair labor requirements.
- Tacori has procedures for the following: reporting violations, confidentiality commitments, and whistleblower protections. Internal whistleblower protections help ensure that workers are free from coercion, intimidation, and involuntary servitude and that they have a meaningful right to organize to improve their lives.
- Additionally, Tacori has several safeguards in place ensuring objective investigations when complaints are filed. We have a developed protocol for internal accountability standards and procedures for employees and contractors failing to meet our company standards regarding slavery and trafficking.
- If/when our company uncovers employee or contractor compliance problems, we provide written notice and a specified period to take corrective action.
- Upon request or need, Tacori can/will conduct visits to our supplier facilities to audit internal grievance mechanisms. We evaluate the existing communication channels in these locations and assessed their adequacy, reviewing the frequency of grievances reported and resolved. We also evaluate the responsiveness of management in addressing anonymous complaints, as well as employee privacy and retaliation concerns.
Training
Tacori is committed to training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chain of products.
- Training sessions/seminars are conducted regularly for employees who are directly responsible for selecting and overseeing suppliers.
- Training sessions/seminars are devoted to mitigating risks of human trafficking and slavery within our company’s supply chains of products.
- Tacori may request or provide additional training on human trafficking and slavery for our employees, contractors, vendors, and suppliers on an as-requested basis, based on an at-risk assessment.
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