CORPORATE RESPONSIBILITY POLICY 

This document formulates the Taché USA Inc. (Taché) corporate responsibility policy, adopted for the benefit of our customers, our employees, our shareholders, and society as a whole. Taché's Corporate Responsibility Policy applies to all of Taché staff, and applies equally to Taché's supply chain and to all suppliers who contribute to the manufacturing of its product. Taché is committed to continuously improve its ethical, social and environmental performance, with the aim of achieving full conformance with the terms of this Policy.

Our vision is defined by the values which underpin our history and determine our future: In keeping with our origin as diamantaires and jewelers, we strive to exceed the limits of excellence. We are conscious of our heritage, and take ownership of our corporate actions. We demand the very best of ourselves, as do our customers. Our customers honor us with their trust. Through our work, behavior and commitment, we endeavor to gain this trust each and every day.

 

THE PRINCIPLES

Business Ethics:

1.  We are committed to conducting our business at a high ethical standard, and to ensure integrity, transparency and conformance with Federal State and Local laws.

2.  We are not engaged and will not tolerate bribery and/or corruption.

3.  We are not engaged in and will not tolerate money laundering and/or the financing of  terrorism.

4.  We adhere to the Kimberley Process Certification Scheme and the World Diamond Council voluntary system of warranties, whose purpose is to put an end to conflict diamond trade. We support similar future initiatives aiming to protect human rights and the integrity of our supply chain.

5.  We disclose the full material characteristics of the products that we sell.

6.  We do act in accordance with all Federal antitrust regulations.

Social Performance:

7.  We believe in and respect the fundamental human rights and the dignity of the individual, according to the United Nations Declaration of Human Rights.

8.  We do not tolerate the use of child labor.

9.  We do not use any forced, bonded, indentured or prison labor, nor restrict the freedom of movement of our employees and dependents.

10. We are committed to high standards of health and safety in all of our operations.

11. We do not prevent workers from associating freely in the workplace. Where laws may prohibit these freedoms, we do support parallel means of dialogue.

12. We do not discriminate based on race, ethnicity, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, marital status, physical appearance, age, or any other applicable prohibited basis in the workplace.

13. We do not use corporal punishment under any circumstances and prohibit the use of degrading treatment, harassment, abuse, coercion or intimidation in any form.

14. We do adhere to working hours and remuneration legislation, or where no such legal requirements have been established by law, we adhere to the prevailing local industry standards.

15. We do take reasonable measures to ensure the physical integrity and security of our employees and the shipments of our product.

16. We do support the development of communities linked to our own activities, contributing to their social and economic welfare.

17. We do recognize and respect the rights of indigenous peoples and the value of their traditional, cultural and social heritage.

Environmental Performance:

18. We do conduct our businesses in an environmentally responsible manner.

19. We do manage our environmental footprint by eliminating and/or minimizing negative environmental impacts resulting from our operations.

20. We do ensure the efficiency of our business operations by managing our waste and our use of water and energy.

 

Principle 1 ‐ We are committed to conducting our businesses at a high Ethical standard, and to ensuring integrity, transparency and conformance with applicable law.

  • We do comply with the applicable laws and regulations relating to our activities in the countries in which we operate.
  • We do strive for continuous improvement of this policy and standards, as a means to support the principles we uphold.
  • We do communicate our responsible vision and policy throughout our organization as well as to our business partners. We do make our policy available to all.
  • We do continue to require high standards within our supply chain in relation to business ethics, and to align our purchasing policy with our business ethics commitment to the fullest extent possible.

Principle 2 - We are not engaged in bribery and/or corruption

  • We do prohibit bribery and corruption in all business transactions carried out by ourselves or through our business associates. We likewise prohibit any action that may compromise the principles of fair competition or constitute an attempt to obtain or retain business or exert influence in the course of our business or in governmental decision making.
  • We do not allow any employee to suffer negative consequences for voicing a concern or in refusing to engage in an act of bribery.
  • We do prohibit acceptance by ourselves as a company, or by any of our employees, of payments, gifts in kind, expenses, discounts, advantages or promises such that may influence the course of our business decisions.

Principle 3 - We do not tolerate money laundering and/or financing of terrorism

  • We do comply with the applicable Federal, State and Local laws and, where appropriate, international and domestic accounting and banking standards and processes (such as independent auditing).
  • We do comply with Federal, State and Local law and where relevant, international and transnationally applicable law with respect to money laundering, financing of terrorism, fraud, and other illegal activities.
  • With respect to the above‐mentioned issues, we do ensure that our  employees are aware of applicable rules and regulations and of our company policy  and that they are kept abreast of their evolutions.
  • We employ a rigorous screening process in order to "know our customer."
  • We do require the same commitments from our business partners who provide us with products and/or services.

Principle 4 - We adhere to the Kimberley Process Certification Scheme (KPCS) and the World Diamond Council voluntary system of warranties, whose purpose are to put an end to conflict diamond trade, and support similar future initiatives aiming to protect human rights and the integrity of our supply chain. We are also compliant with RJC Standards for Gold Purchases as well as all relevant areas of the Dodd-Frank Legislation.  

  • We do not buy conflict diamonds or assist others to do so.
  • Our diamond purchases are made in accordance with the KPCS and System of Warranties. A supplier statement of warranty is required on all invoices concerning diamonds received by Taché.
  • We do keep invoices received, pertaining to the purchase of diamonds, for a minimum period of 5 years for audit and reconciliation purposes.
  • We do suspend any supplier relationship in which our supplier is suspected of being involved in conflict diamond trade until we obtain assurances that no such trade dealings are taking place, or that such dealings were taking place without knowledge on the part of the supplier and that the supplier has taken all appropriate measures to end such dealings.
  • We do terminate any supplier relationship in which our supplier is found to be knowingly involved in conflict diamond trade and will reserve the right to prosecute the supplier accordingly.
  • We do ensure that company employees that buy or sell diamonds are well informed about the Kimberley Process, government restrictions on the trade in conflict diamonds and their duty to abide by Taché policy requirements. We will regularly update our staff on the issue of conflict diamonds and Taché policy in respect to diamond purchasing.
  • Beyond the Kimberley Process and the voluntary system of warranties adopted by the diamond industry, we do support and will implement any further procedures or processes agreed together by the diamond industry, governments, and civil society representatives aiming to put an end to trade in conflict diamonds.
  • We will play a proactive role to encourage and support similar endeavors, for instance in the area of gemstones and precious metals and, to this effect, will engage with others in order to define and promote appropriate measures.
  • Our Gold is sourced only through LBMA certified gold vendors and is tracked and controlled from purchase through its sale to the retailer.

Principle 5 - We disclose the material characteristics of the products that we sell

  • We do comply with the relevant trading standards legislation, and where they exist, specific Federal, State and Local regulations and generally accepted industry guidelines applicable to the types of products we sell.
  • We do disclose, to our clients and prospective clients, relevant information on the material characteristics of our products, such as, for diamonds: weight, cut, color, clarity and metals type, alloy and weight in accordance with recognized Federal, State Local and International guidelines.
  • We do not make any untruthful, misleading, or deceptive statement, representation or material omission in the promotion or advertising of our products.
  • We adhere to high standards of product quality and safety.
  • We do  ensure adequate training of our staff on our history, heritage, products, and policies in order for them to provide full customer experience and reliable information to clients and prospective clients.

Principle 6 - We do act in accordance with anti-trust regulations

  • We do comply with applicable Federal anti‐trust laws and regulations.
  • We do not seek to make use of our membership in trade organizations to obtain or exchange commercially sensitive information in contradiction to Federal, State and Local competition laws and regulations.

Principle 7 - We believe in and do respect the fundamental human rights and the dignity of the individual, according to the United Nations Declaration of Human Rights

  • We do uphold the United Nations Universal Declaration of Human Rights within our operations and in relation to and from our business partners.

Principle 8 ‐ We do not tolerate the use of child labor

  • We do not, in any country engage in the employment of children.
  • We require that our business partners who provide us with products and/or services comply with the child and young person’s employment guidelines agreed by the Council for Responsible Jewellery Practices.

Principle 9 – We do not use any forced, bonded, indentured or prison labor, nor restrict the freedom of movement of employees and dependents    

  • We do ensure that all work performed on behalf of ourselves within our operations is based on recognized employment relationships.
  • We do not retain originals of employee personal documentation (such as identity papers), nor require any form of deposit or fee as a condition of employment.
  • We do require the same commitments from our business partners who provide us with products and/or services.
  • We do adhere to applicable Federal, State and Local employment laws and regulations.

Principle 10 – We are committed to high standards of health and safety in our operations

  • We do provide safe and healthy working conditions for all employees in accordance with applicable laws and regulations.
  • We do take appropriate measures to prevent accidents, injury, and health problems arising from or linked to the course of work activities, in our operations.
  • We do ensure that employees are aware of specific role-related health and safety risks and potential hazards, along with methods for appropriate protection from such hazards, and actions to be taken in the event of an accident.
  • We do ensure that our workplace constitutes an adequate working environment in accordance with required standards (lighting, ventilation, air quality, noise levels and temperature).
  • We offer workplaces which are adequately constructed and maintained to meet local building regulations.
  • We ensure employees have access to a mechanism by which they can raise and discuss health and safety issues with management.
  • We do monitor health and safety issues and adequately address such issues that arise.
  • We do ensure that appropriate measures are employed to minimize the risk of employee contact with hazardous substances, through the use of protective equipment and gear, the use of appropriate containers, and posting of safety notices.
  • We do not make use of substances that are subject to Federal, State, Local or international bans for their adverse effects on humans or the environment.
  • We require our business partners who supply us with product and business services to comply with the above‐mentioned commitments and, where appropriate, provide them with assistance in meeting these standards.

Principle 11 – We do not prevent workers from associating freely. Where laws prohibit these freedoms, we do support parallel means of dialogue

  • We do adhere to applicable law and collective bargaining agreements where such agreements exist.
  • Where such agreements do not exist we do support the implementation of collective employee representation and a robust and effective dialogue between management and employees.
  • We do require our business partners who provide us with products and/or services to comply with the above‐mentioned commitments.
  • Every employee is required to sign the Taché Whistleblower Policy.

Principle 12 - We do not discriminate based on race, ethnicity, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation, marital status, physical appearance, age, or any other applicable prohibited basis in the workplace

  • We do not practice or condone any form of discrimination in the workplace.
  • We do observe the right to freedom of practice by employees of religious or cultural practices, as far as is reasonable.
  • We do provide appropriate training to our employees on a continued basis, in order for them to acquire, maintain and further the skills which will provide them with access to career opportunities.
  • We do require our business partners who provide us with products and/or services to comply with the above‐mentioned commitments.

Principle 13 – We do not use corporal punishment under any circumstances and do prohibit the use of degrading treatment, harassment, abuse, coercion or intimidation in any form

  • We do not make use of or condone such practices.
  • We clearly communicate applicable disciplinary processes and procedures to our employees.
  • We do ensure that grievance procedures and investigation processes are in place and are communicated to all employees.
  • We do require our business partners who provide us with products and/or services to comply with the above‐mentioned commitments.

Principle 14 – We do adhere to working hours and remuneration legislation, or, where no such legal requirements have been established by law, the prevailing local industry standards

  • We do ensure that normal working hours comply with Federal, State and Local legislation.
  • We do provide weekly rest and paid annual leave in accordance – at a minimum – with Federal, State and Local legislation and applicable sector regulations.
  • We do abide by all legally mandated provisions for leave, including maternity/paternity, and compassionate leave.
  • We do ensure that employees are paid with due regard to industry standards and at least according to the applicable legal minimum wage and record of payment (wage slip) compliant with Federal, State and Local legislation.
  • We do not make illegal deductions from wages for disciplinary purposes.
  • We do ensure fair terms and conditions to our business partners who provide us with products and/or services, to the best of our ability, including sufficient notice on planning schedules and payment within an agreed and reasonable timeframe.

Principle 15 – We do take reasonable measures to ensure the physical integrity and security of our employees and product shipments

  • We do take appropriate measures to ensure the physical integrity and security of our employees dealing with valuables (product components, semi-finished and finished products) in our operations and during transportation to and/or from our operations.
  • We do ensure that all security personnel respect the human rights and dignity of all people and use the minimum force proportionate to the threat.
  • We do require our business partners who provide us with products and/or services to comply with the above‐mentioned commitments.

Principle 16 – We do support the development of communities linked to our own activities, contributing to their social and economic welfare

  • We endeavor to develop programs supporting communities historically involved in our supply chain, with the aim to contribute to their social and economic welfare.
  • We encourage our employees in their involvement in community programs aiming at bettering society, and support them where appropriate.

Principle 17 – We do recognize and respect the rights of indigenous peoples and the value of their traditional, cultural and social heritage

  • We do require of our business partners who provide us with products and/or services that they recognize and respect the rights of indigenous peoples and the value of their traditional, cultural and social heritage.

Principle 18 – We do conduct our businesses in an environmentally responsible manner

  • We do ensure compliance of our site(s) with relevant legal requirements, environmental norms and specific industrial environment regulations and have appropriate mechanisms in place to keep management and key staff up to date.
  • We do comply with applicable conventions and regulations regarding the protection of endangered species.
  • We seek to minimize the use of hazardous substances in our jewelry production processes and use alternatives wherever technically feasible and possible.
  • We ensure that hazardous waste substances arising from the production of our jewelry is disposed of in a manner which prevents pollution of the surrounding land, water resources and atmosphere.
  • We encourage continuous improvement within our supply chain in relation to environmental performance, and seek to align our purchasing policy with our environmental commitments.
  • We do require our business partners who provide us with products and/or services to comply with the above‐mentioned commitments.

Principle 19 – We do manage our environmental footprint by eliminating or minimizing negative environmental impacts resulting from our operations

  • We seek to factor appropriate environmental considerations into the development of our processes, technologies, products and packaging in order to optimize environmental performance.
  • We ensure that facilities managers are aware of specific pollution risks, methods for appropriate prevention, and action to be taken in the event of an incident.
  • We do require our business partners who provide us with products and services to comply with the above‐mentioned commitments.                                        

Principle 20 – We do ensure the efficiency of our business operations by managing our waste and our use of water and energy

  • We do take steps to reduce the quantity of general waste produced from our operations through the principles of reduce, recover, re‐use and recycle.
  • We do take steps to reduce the quantity of water and energy consumed in our operations.
  • We do seek to assure the implementation practices that reduce use of fossil fuels and associated greenhouse gas emissions from transportation.
  • We do require our business partners who provide us with products and/or services to comply with the above‐mentioned commitments.