Responsible Business Practice Policy

This policy operates to define Becks Group Australia (BECKS) - A Division of Peter W Beck Pty Ltd - commitment to operate its business consistent and compliant with a goal of being socially, morally, and environmentally responsible. It further demonstrates its commitment to maintaining a sustainable business model relative to its refining practices in the precious metal and jewellery supply chain, and compliance with applicable standards.

BECKS is a member of the Responsible Jewellery Council (RJC).

The RJC is an external third-party auditor established to develop and measure benchmark standards and Codes of Compliance for the precious metal/gemstone and jewellery manufacturing and supply chain industry.

Membership of the RJC obligates BECKS to meet and comply with the benchmark standards including Code of Practice (COP) and Chain of Custody (COC).
Our RJC membership validates our commitment to operating business in the highest standards of ethics, human rights, social and environmental practices. The BECKS Compliance Officer is the responsible person for managing and maintaining standards.

BECKS is committed to ensuring that it demonstrates an operating and trading model that in practice:

• Upholds ethical business practices
• Upholds the fundamental application and recognition of human rights standards
• Promotes the efficient use and protection of resources, energy, recycling, biodiversity and reducing its emissions and carbon footprint
• It will comply with applicable legislation by implementing policy, procedures and methods that mitigate and manage commercial and trading risks associated with contractors, suppliers, partners and any relevant stakeholder.

The broad application of the Responsible Business Practice Policy is underpinned by the following:

1. BUSINESS ETHICS

• We are committed to conducting our businesses to a high ethical standard, and to ensuring integrity, transparency and conformance with Applicable Law.
• We shall not engage in Bribery and/or corruption.
• We shall not tolerate Money Laundering and/or financing of terrorism.
• We shall adhere to the Kimberley Process Certification System and the World Diamond Council Voluntary System of Warranties.
• We shall fully and accurately disclose the material characteristics of the products that we sell.
• We shall take reasonable measures to ensure the physical integrity and security of product shipments.
• We shall respect commercial confidentiality and data privacy.

2. HUMAN RIGHTS AND SOCIAL PERFORMANCE

• We believe in and shall respect the fundamental human rights and the dignity of the individual, according to the United Nations Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights and the International Labour Organisation.
• We shall not tolerate the use of Child labour.
• We shall not use any forced, bonded, indentured or prison labour, nor restrict the freedom of movement of employees and dependents.
• We are committed to high standards of Health and safety in our operations.
• We shall not prevent workers from associating freely. Where laws prohibit these freedoms, we shall support parallel means of dialogue.
• We shall 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, such that all individuals who are “Fit for Work” are afforded equal opportunities and are not discriminated against on the basis of factors unrelated to their ability to perform their job.
• We shall not use corporal punishment under any circumstances and shall prohibit the use of degrading treatment, harassment, abuse, coercion or intimidation in any form.
• We shall adhere to working hours and remuneration legislation, or, where no such legal requirements have been established by law, the prevailing industry standards.
• We shall support the development of communities where we operate, contributing to their social and economic welfare.
• We shall recognize and respect the rights of indigenous peoples and the value of their traditional, cultural and social heritage.

3. ENVIRONMENTAL PERFORMANCE

• We shall conduct our business in an environmentally responsible manner.
• We shall manage our environmental footprint by eliminating or minimizing negative environmental impacts.
• We shall ensure the efficiency of our business operations by managing our use of resources and energy.
• We shall adopt practices to enhance biodiversity and reduce negative impacts on biodiversity.

4. MANAGEMENT SYSTEMS

• We shall comply with Applicable laws and publicly state our commitment to the RJC Code of Practices.
• We shall assess our risks, including risks to our business from our business partners, and establish systems that manage and improve ethical, human rights, social and environmental business practices.

5. SUPPLY CHAIN MANAGEMENT

BECKS Supply Chain Management Policy extends our commitments, policies, and value to our entire value chain and to encourage our suppliers, providers, and contractors to comply with these commitments.

This policy confirms our commitment to respect human rights, avoid contributing to the finance of conflict and comply with relevant UN sanctions, resolutions and laws.
We do not engage in or tolerate bribery, corruption money laundering or finance terrorism, support transparency of government payments and rights compatible security forces in the extractives industry, do not provide direct or indirect support to illegal armed groups, enable stakeholders to voice concerns about the jewellery supply chain and are implementing the OECD five-step framework as a management process for risk-based due diligence and responsible supply chains of minerals from conflict affected and high risk areas.

I. Regarding serious abuses associated with the extraction, transport or trade of gold

We will neither tolerate nor profit from, contribute to, assist or facilitate the commission of:

• torture, cruel, inhuman and degrading treatment;
• forced or compulsory labour;
• the worst forms of child labour;
• human rights violations and abuses; or
• war crimes, violations of international humanitarian law, crimes against humanity or genocide.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are committing abuses described in paragraph I or are sourcing from, or linked to, any party committing these abuses.

II. Regarding direct or indirect support to non-state armed groups

We will not tolerate direct or indirect support to non-state armed groups, including, but not limited to, procuring gold from, making payments to, or otherwise helping or equipping non-state armed groups or their affiliates who illegally:

• control mine sites, transportation routes, points where gold is traded and upstream actors in the supply chain; or
• tax or extort money, or gold at mine sites, along transportation routes or at points where gold is traded, or from intermediaries, export companies or international traders.

We will immediately stop engaging with upstream suppliers if we find a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups as described in paragraph II.

III. Regarding public or private security forces

We affirm that the role of public or private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses described in paragraph I, or that act illegally as described in paragraph II.

IV. Regarding bribery and fraudulent misrepresentation of the origin of gold

We will not offer, promise, give or demand bribes, and will resist the solicitation of bribes, to conceal or disguise the origin of gold, or to misrepresent taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of gold.

V. Regarding money laundering

We will support and contribute to efforts to eliminate money laundering where we identify a reasonable risk resulting from, or connected to, the extraction, trade, handling, transport or export of gold.

6. PRODUCT DISCLOSURE

BECKS will not knowingly make any untruthful, misleading or deceptive representation, or make any material omission in the sale or marketing of our products, services, methods of production or materials. BECKS will disclose the characteristics consistent with the applicable RJC Code of Practices standard.

7. GRIEVANCE PROCEDURE

BECKS will receive any formal complaint, question or concern from an interested party or stakeholder relative to our supply chain or business practice. Grievances can be raised via email to the Compliance Officer or by phone.

This procedure is separate from our complaints handling process in relation to privacy related matters.

Email for grievances: compliance@becksgroup.au
Phone number for grievances: 1800 888 528 (toll free)

BECKS will aim to:

• Respond to any question, query or complaint within 48 hours to gather more information or clarify any grievance if required
• Identify and report on any action required or taken
• Report on any decided action or outcome
• Keep records of complaints, questions or queries received for 5 years